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NO.

07-16-00320-CV

IN THE SEVENTH COURT OF APPEALS


AMARILLO, TEXAS

Timothy Castleman and


Castleman Consulting, LLC,
Appellants,
v.
Internet Money Limited and
Kevin OConnor,
Appellees.
On Appeal from the 237th District Court of Lubbock County, Texas
The Honorable Les Hatch Presiding

Appellees Verified Original Application for Temporary


Restraining Order and Temporary Injunction
FIELD, MANNING, STONE,
HAWTHORNE & AYCOCK, P.C.
A Professional Corporation
2112 Indiana
Lubbock, Texas 79424
806-792-0810 (Telephone)
806-792-9148 (Facsimile)
Anna McKim
State Bar No. 24033381
J. Paul Manning
State Bar No. 24002521
ATTORNEYS FOR APPELLEES
EXPEDITED ACTION REQUESTED
ORAL ARGUMENTS REQUESTED

IDENTITIES OF PARTIES AND COUNSEL


PARTIES

COUNSEL

Appellants
Timothy Castleman and
Castleman Consulting, LLC

The Olson Firm. PLLC


PMB 188
Leif A. Olson
4830 Wilson Road, Ste. 300
Humble, TX 77396
(281) 849-8382
The Law Office of Jared B. Hall,
PLLC
Jared B. Hall
PO Box 6982
Lubbock, TX 79493
(806)

Appellees
Internet Money Limited and
Kevin OConnor

Field, Manning, Stone,


Hawthorne & Aycock, P.C.
Mr. J. Paul Manning (Trial)
Ms. Anna McKim (Appeal)
2112 Indiana
Lubbock, Texas 79410
(806) 792-0810 (Telephone)
(806) 792-9148 (Facsimile)

ii

TABLE OF CONTENTS
IDENTITIES OF PARTIES AND COUNSEL .................................................... ii
I. DESIGNATION OF PARTIES...........................................................................1
II. JURISDICTION AND VENUE ........................................................................2
III. STATEMENT OF THE CASE .......................................................................2
IV. APPLICATION FOR TEMPORARY RESTRAINING ORDER,
TEMPORARY INJUNCTION AND PERMANENT INJUNCTION ........3
V. CONCLUSION ...................................................................................................6
VI. PRAYER FOR RELIEF ..................................................................................6
CERTIFICATE OF COMPLIANCE ....................................................................7
CERTIFICATE OF SERVICE ..............................................................................8
VERIFICATION......................................................................................................9
APPENDIX .............................................................................................................10

IN THE COURT OF APPEALS


FOR THE SEVENTH DISTRICT OF TEXAS
AT AMARILLO
TIMOTHY CASTLEMAN AND

CASTLEMAN CONSULTING, LLC,


Appellants,

Cause No. 07-16-00320-CV


vs.

INTERNET MONEY LIMITED

AND KEVIN OCONNOR,

Appellees.

APPELLEES VERIFIED ORIGINAL APPLICATION FOR TEMPORARY


RESTRAINING ORDER AND TEMPORARY INJUNCTION

COMES NOW Appellees, INTERNET MONEY LIMITED

AND

KEVIN

OCONNOR, complaining of Appellants, TIMOTHY CASTLEMAN AND CASTLEMAN


CONSULTING, LLC, and would show the Court as follows:
I. DESIGNATION OF PARTIES
1.

Appellants, TIMOTHY CASTLEMAN

AND

CASTLEMAN CONSULTING,

LLC, have made an appearance in this lawsuit by and through their attorney of
record Jared Hall and Lief Olson.
2.

Appellee, INTERNET MONEY LIMITED, has made an appearance in this

action by and through its attorney of record, J. Paul Manning.


3.

Appellee, KEVIN OCONNOR is an individual who has made an

appearance in this action by and through his attorney of record, J. Paul Manning.
1

II. JURISDICTION AND VENUE


4.

Jurisdiction and venue are proper in the Court of Appeals for the 7th

District of Texas because at the time of the conduct made the basis of Appellees
Verified Original Application for Temporary Restraining Order and Temporary
Injunction, this Court had jurisdiction over the parties pursuant to TEXAS RULE OF
APPELLATE PROCEDURE 52.1.
III. STATEMENT OF THE CASE
5.

In late November 2015, Appellants began an intentional and specific

campaign to defame Appellees. (CR 1:88) Appellants took to multiple forums


including Facebook, Twitter, a blog, Warrior Forum, Google Reviews, and podcasts
to publish false and misleading accounts of Appellants dealings with Appellees.
(CR 1:87-89) The statements were made with knowledge of their falsity or, at the
very least, recklessly. (CR 1:89) In fact, Appellants recognized and gloated about
the damage Appellants were causing Appellees and continue to do so during the
pendency of this appeal. (CR1:89)
6.

Despite this lawsuit, Appellants continue to make false defamatory and

disparaging comments regarding Appellees to a myriad of third parties via social


media and various other platforms and publish defamatory comments industry-wide
compounding the injurious impact upon Appellees. (Ex. B)
7.

The harassment continued in December 2015 as Appellants directly

contacted Appellees. (Ex. A) Appellees initial counsel requested Appellants


attorney have Appellants refrain from direct contact with Appellees. (Ex. A-1)
8.

Notwithstanding, on July 23, 2016, Appellants contacted Appellees via

email threatening and attempting to goad Appellants into improper discourse. (Ex.
A-2) On August 11, 2016, Appellants directly contacted counsel for Appellees. (Ex.
A-3) Appellees counsel contacted Appellants counsel, Jared Hall, requesting the
direct contact with Appellees and his counsel stop immediately. (Ex. A-4)
Appellees counsel advised that Appellants had been instructed against direct
contact. (Ex A-4)
9.

Instead of compliance, Appellants wrote the following related to the

communications with Appellees and their counsel. (Ex. A-5)


10.

On October 7, 2016, Appellants intentionally contacted Appellees with

the additional threats and intimidating language. (Ex. A-6) Again, on November 8,
2016 Appellant directly contacted Appellee. (Ex. A-7) Appellee, Kevin OConnors
wife is pregnant, and the intimidating and harassing nature of the contact by
Appellants has unnerved both Mr. and Mrs. OConnor. (Ex. A)
IV. APPLICATION FOR TEMPORARY RESTRAINING ORDER,
TEMPORARY INJUNCTION AND PERMANENT INJUNCTION
11.

Appellees incorporate by reference the allegations made in the

foregoing paragraphs 1-10.

12.

For the last few months, Appellants have been playing a cat and mouse

game with Appellees, attempting to goad them into an inappropriate online fight. At
every opportunity, Appellees have taken the high road refusing to respond. Despite
repeated requests by Appellees counsel for Appellants to refrain, Appellants
continuously and systematically refuse to stop directly contacting Appellees or
posting items about them online. Appellants actions have caused anxiety, fear, and
harassment to Appellees and Mr. OConnors pregnant wife.
13.

Appellants

actions

leave

no

doubt

they

intentionally

and

systematically desire to harass, intimidate, and bully Appellees as part of an overall


litigation scheme. Appellants actions have and will cause Appellees immediate and
irreparable harm unless immediately enjoined by this Court. Unless a temporary
restraining order, as prayed for below, is granted, the Appellees will suffer
immediate and irreparable injury, loss, or damage before notice can be served and a
hearing had on its request for injunctive relief. Accordingly, the Appellees request
that this Court issue a temporary restraining order pursuant to Texas Rule of Civil
Procedure 680.
14.

Appellees have no adequate remedy at law and are suffering immediate,

imminent, and irreparable harm. Monetary damages alone are not sufficient to
redress the imminent and irreparable harm to Appellees.

15.

Appellees enjoy a substantial likelihood that they will prevail on the

merits of their claims and a probable right to relief. The equities in this matter weigh
heavily in favor of Appellees, as Appellees seek only to preserve the status quo
pending trial, appeal, and/or other resolution of the parties dispute.
16.

Appellants will suffer no harm as a result of this injunction.

17.

Appellees are willing to post a bond in the reasonable amount this Court

deems appropriate, even though it is not required by law.


18.

In accordance with TEXAS CIVIL PRACTICES

AND

REMEDIES CODE

65.001, et. seq., and TEXAS RULES OF APPELLATE PROCEDURE Rule 52.1, to prevent
Appellees from suffering the aforementioned non-monetary penalty of fear, anxiety,
and harassment, Appellees ask this Court to preserve the status quo and grant a
temporary restraining order and temporary injunction against Appellants to enjoin
Appellants from contacting, threatening, emailing, posting in social media and
posting any comments, videos, pictures about Appellees by their agents, attorneys,
employees or family and communicating with Appellees or Appellees counsel in
person or in any other manner, including by telephone or another electronic voice
transmission, video chat, in writing, or electronic messaging during the pendency of
this litigation. Appellees further seek a permanent injunction against Appellants
from further engaging in the proscribed activities set forth above.

V. CONCLUSION
For the reasons stated herein, Appellees ask this Court to enter a temporary
restraining order and temporary injunction to allow Appellees to protect themselves
and their rights and to attorney fees.
VI. PRAYER FOR RELIEF
FOR THESE REASONS, the Appellees request and pray that:
1.
The Court enter a temporary restraining order enjoining Appellants, and
any of their agents, servants, or employees,
a.

Contacting, threatening, emailing, posting in social media and posting


any comments, videos, or pictures about Appellees, their agents,
attorneys, employees or family; and

b.

Communicating with Appellees or Appellees counsel in person or in


any other manner, including by telephone or another electronic voice
transmission, video chat, in writing, or electronic messaging during the
pendency of this litigation;

2.
Appellants be cited to appear and show cause and that upon hearing, a
temporary injunction be issued enjoining Appellants, and any of their agents,
servants, or employees, from directly or indirectly contacting, threatening, emailing,
posting in social media and posting any comments, videos, pictures about Appellees;
and communicating with Appellees or Appellees counsel in person or in any other
manner, including by telephone or another electronic voice transmission, video chat,
in writing, or electronic messaging during the pendency of this litigation;
3.
Attorneys fees expended in this cause in such amount as may be found
reasonable by the Court;
4.

Costs of court; and

5.
Such other and further relief the court deems appropriate to which
Appellees may show itself justly entitled either at law or in equity.

Respectfully submitted,
FIELD, MANNING, STONE,
HAWTHORNE & AYCOCK, P.C.
A Professional Corporation
2112 Indiana Avenue
Lubbock, Texas 79410-1499
806/792-0810 (Telephone)
806/792-9148 (Facsimile)
Email: jpmanning@lubbocklawfirm.com
BY: /s/J. Paul Manning
J. PAUL MANNING
State Bar No. 24002521
Attorneys for INTERNET MONEY LIMITED
AND KEVIN OCONNOR,

CERTIFICATE OF COMPLIANCE
Pursuant to TEXAS RULES OF APPELLATE PROCEDURE Rule 52.10, counsel for
Appellees has notified counsel for Appellants, Jared Hall, that this application will
be filed.
/s/J. Paul Manning
J. PAUL MANNING

CERTIFICATE OF SERVICE
A true and correct copy of the above and foregoing instrument was on this
22 day of November, 2016, served on the attorneys of record as follows:
nd

Email: jhallattorney@gmail.com
Fax: 866-870-2072
JARED B. HALL
THE LAW OFFICE OF JARED B. HALL, PLLC
PO BOX 6982
Lubbock, TX 79493
Email: leif@olsonappeals.com
LEIF A. OLSON
THE OLSON FIRM, PLLC
4830 Wilson Road, Ste. 300
Humble, TX 77396
/s/J. Paul Manning
J. PAUL MANNING

APPENDIX
Exhibit A - Affidavit of Kevin OConnor ...................................................... Tab 1
Exhibit A-1 ........................................................................................................ Tab 2
Exhibit A-2 ........................................................................................................ Tab 3
Exhibit A-3 ........................................................................................................ Tab 4
Exhibit A-4 ........................................................................................................ Tab 5
Exhibit A-5 ........................................................................................................ Tab 6
Exhibit A-6 ........................................................................................................ Tab 7
Exhibit A-7 ........................................................................................................ Tab 8
Exhibit B ........................................................................................................... Tab 9

10

IN THE COURT OF APPEALS


FOR THE SEVENTH DISTRICT OF TEXAS
AT AMARILLO
TIMOTHY CASTLEMAN AND

CASTLEMAN CONSULTING, LLC,


Appellants,

Cause No. 07-16-00320-CV


vs.

INTERNET MONEY LIMITED

AND KEVIN O'CONNOR,


Appellees.

AFFIDAVIT OF KEVIN O'CONNOR

REPUBLIC OF IRELAND
COUNTY OF KILDARE

BEFORE ME, the undersigned authority, on this day appeared KEVIN


O'CONNOR, personally known to me, who upon being first duly sworn, upon his
oath deposes and testifies as follows:
"My name is KEVIN O'CONNOR. I am over the age of eighteen years, am of
sound mind, and am fully competent to testify to the matters contained herein.
"The statements made herein are made on personal knowledge, and the
statements made herein are true and correct.
1. I am an Appellee in this lawsuit and also the principal of Internet Money
Limited d/b/a The Offline Assistant, the other Appellee in this lawsuit.
2. The attached Exhibit B are true and correct copies ofblog entries, Facebook
posts, Warrior Forum post, and YouTube videos that Castleman and
Castleman Consulting, LLC has posted related to my company, my attorneys
and myself since the commencement of this lawsuit.

Page 1

Affidavit

Exhibit "A"

3. The attached Exhibits (A:I-A:7) are true and correct copies of emails I have
received from Tim Castleman directly since the commencement of this
lawsuit and requests sent by Appellees attorneys requesting him not to directly
contact me.
4. In the normal course of business, I received and/or investigated the emails and
status of Castleman and Castleman Consulting, LLC were sending, posting
and blogging and I pulled and copied same. Exhibits A-B are true and correct
copies of these certain copies I found in the normal course of business.
5. My wife is pregnant with our first child and the emails received from
Castleman and Castleman Consulting, LLC have caused increased anxiety,
apprehension and fear to both of us.

"I DO SOLEMNLY AFFIRM under the penalties of perjury and upon


personal knowledge that the contents of the foregoing paper are true.
Further Affiant saith not."
Signed this

.J..~

"-"-

day of November 2016.

Kevin O'Connor

SUBSCRlBED AND SWORN TO ME on this the 1~ wA.dg. of November,


2016.

,........-------~NOTARY PUBLIC, in and for said county


/
and state E.(Ernan) Rory O'Connor, Oip.Not.L
./J''''.

Notary Public
I

4 lucan lodge,
lucan, Co. Dublin
Ireland

Tel. (353 -1-) 628(}S17

:.1

(COUMISSIONED FOR LIFE!.,


Affidavit

Page 2

From: Zachary Farrar


Sent: Tuesday, December 29, 20153:11 PM
To: 'jhallattorney@gmail.com'
Cc: Stacie Burgess

Subject: Kevin O'Connor and The Offline Assistant Response to Your Demand Letter Dated December 14, 2015

Mr. Hall,

I hope that you had a wonderful Christmas holiday and that the weather in Lubbock has been more pleasant
than here in DFW.

Attached, please find a copy of Mr. O'Connor's and The Offline Assistant's response to your demand letter
'ated December 14, 2015. After you have had time to review the letter and speak with your client, I look
forward to discussing with you the facts giving rise to this dispute. In addition to the attached copy, a hard copy
of the response is being mailed to your office.

On a separate note, Mr. O'Connor has relayed to me that Mr. Castleman has emailed him multiple times in the
past few weeks. As my firm and I are representing Mr. O'Connor and The Offline Assistant, I respectfully
request that you tell Mr. Castleman to direct any future inquiries or communications related to this dispute to
me and my firm, not Mr. O'Connor.

Lastly, after this response was drafted, it came to light that Mr. Castleman had "charged back" approximately
<l)2,000.OO worth of work that The Offline Assistant performed, resulting in the deduction of The Offline
Assistant's bank account. In short, The Offline Assistant performed services for Mr. Castleman and Castleman
Consulting, LLC; Mr. Castleman and Castleman Consulting, LLC enjoyed those services; Mr. Castleman and
Castleman Consulting, LLC were enriched by those services, however, The Offline Assistant has not been
compensated for those very services. This issue must be addressed in addition to those discussed in the
attached response.

I look forward to hearing from you. As always, please feel free to call with any questions or concerns.

Sincerely,

Zachary C. Farrar

Exhibit "A-1"

Moses. Palmer & Howell, L.L.P.


Oil & Gas Building
309 West 7th Street, Suite 815
Fort Worth, Texas 76102
817.255.9100 - Main
~17.255.9105 -

Direct Dial

817.255.9199 - Facsimile
zfarrar@mph-Iaw.com

Primerus
THIS E-MAIL AND ITS ATTACHMENTS MAYBE CONFIDENTIAL AND/OR PRIVILEGED. IF YOU
, ARE NOT AN INTENDED RECIPIENT, PLEASE NOTIFY THE SENDER BY REPLY E-MAIL AND
DESTROY ALL COPIES OF THESE MATERIALS. UNLESS STATED OTHERWISE, NOTHING HEREIN
IS INTENDED TO BE AN ELECTRONIC SIGNATURE.

---------- Forwarded message ---------From: Tim Castleman <timothycastleman@gmail.com>


Date: Sat, Ju123, 2016 at 2:06 AM
Subject: Congrats?
To: Kevin O'Connor <Kevin@theofflineassistant.com>, Kevin O'Connor <kwoconnor@gmail.com>, Kevin
OConnor <theofflineassistant@gmail.com>

Kevin Looks like the judge wants this lawsuit of yours to continue.
I hope your lawyer isn't actually charging you for the 3 hours he sat waiting for the case to be heard like he tried
to do to me when he submitted his bill to the court.
Or the fact he's the one who is having to write up the paperwork for the judge.
Guess you have to pay for that as well?
$6500 in attorneys fees for you already according to his filing (I'd check it to be sure)?
He isn't even using paralegals for this case, 100% lawyers only apparently (at least from what I saw on his
billing sheet he submitted).
Ouch, and you owe me what - $8k?
And this is after I offered to settle with you for less than that amount several times to end this mutually way
before we even spent a dime here.
I mean now you have to pay your lawyers fees for the appeal cost, then the trial itself, our lawsuit against you,
appeals from both parties, and more.
1

Exhibit "A-2"

And if you lose, you might not only have to pay the amount you owe me, but possibly also my lawyers fees as
well, and maybe some damages on top of that?
How much do you think this is going to end up costing when we're all done here?
20k+? I don't think the legal system is in any hurry to see us finish this anytime soon.
Why would they right - it's the lawyers who are getting paid so why would they want it to end?
This thing could drag on for a few years before we're done with it.
I don't remember the exact numbers but I thought your guy said he'd be charging like $12,000 to do the appeal
(but I don't have the paperwork in front of me). Then if that doesn't go well, we start all over with your trial, our
lawsuit against you (spoiler alert), and then the appeals from each party.
Now that we're moving forward I guess you'll be coming to Lubbock several times for the trial, deposition,
hearings, and the trial.
I'm sure there are discounted flights from Ireland to Lubbock for to you take advantage of and I can make some
hotel recommendations if you'd like for when you get here.
And I'm also sure your lawyer is going to ask that I don't contact you and speak to him directly so I'll save you
both the trouble:
No.
If either of you have a problem with it you both know my address and you can come talk to me personally, but
we both know that won't happen, right?
Tim

ps: The opinions expressed here are just my thoughts and ideas and not based on any factual information or
statements and for the love of God should not be taken seriously without doing your own due diligence first.
They are the statements of Tim Castleman, President of Castleman Consulting LLC and not that of Tim
Castleman personally.

When in doubt, hug a lawyer, they need it.

This email has been scanned for spam and viruses by Proofpoint Essentials. Click here to report this email as
spam.

J. Paul. Manning
Tim Castleman <timothycastleman@gmail.com>
Wednesday, August 10, 2016 6:14 PM
Kevin OConnor; Kevin OConnor; Kevin OConnor; Jared B. Hall; Leif Olson; J. Paul.
Manning
False YouTube Report By Kevin OConnor (Please remove by (8/19)
YouTube.jpg; UnitedStates.jpg

From:
Sent:
To:
Subject:
Attachments:

Mr. Manning:
Your client appears to have filed a false and misleading request to have MY copyright protected content (that
was created here in the United States by my company (a US based company) blocked from Ireland.
The country of this dispute is not Ireland like Mr. OConnor falsely reported, but the United States (where I am
licensed to do business). Again, this appears to be a knowingly false claim by your client in an attempt to
circumvent the US legal system.
As you can see by the attached screenshots (you feel free to do your research as well
https://support.google.com!youtube/answer/6154230?hl=en select the United States), YouTube specifically
states that it will NOT remove content created in the United States without a written court approval.
-

You have none.


That is why he appears to have falsely selected Ireland as the country of dispute. Mr. OConnor was also a visa
resident of the United States at the time of this dispute.
As a result your client has interfered with my business and blocked my content from appearing world wide with
this false report. I explained to your client in no uncertain terms that if he attempted to remove or alter my
content again I would then be forced to update my entire customer base with his doings.
Your client has 7 business days to get my content unblocked in Ireland (where I do not work, my business and
my content is subject to US laws and copyright) or I will follow through with alerting my customer base of Mr
OConnors latest antics along with having my lawyers alert the judge of this false report by Mr. OConnor.
It doesnt matter that Mr. OConnor might have snuck back to his home country and refused to report any
location information to avoid being sued by us, but it does-matter that this is a matter of our ongoing court case
here in the United States and not in Ireland like he falsely reported.
I dont need a response by either of you, just make it happen and if you cant please be ready to to explain to the
judge (in person) why you did this.
Leif and Jared if you could also check with the court on the status of the report that was to be prepared by
Mr. Manning some time ago. Id like to get our appeal going.
-

If the content isnt fully restored by the 19th of August, please alert the judge and I would ask that we schedule
an in person hearing (that requires Mr. OConnors in person attendance) to explain this.
Thanks.
1

Exhibit "A-3"

Tim Castleman, Castleman Consulting LLC. President

Sandra Meeks
From:
Sent:
To:
Subject:

Jared B. Hall <jhallattorney@gmail.com>

Friday, August 12, 2016 8:21 AM


J. Paul. Manning
Re: OConnor v Castleman

Ive told Tim he is not to contact either you or Kevin; that all communications are to be to me or Lief only.
Thanks,
Jared
Jared B. Hall
The Law Office of Jared B. Hall, PLLC
P0 Box 6982
Lubbock, TX 79493
(806) 853-7182
(866) 870-2072 fax
This email and all attachments may be covered by attorney client privilege. If you are not the intended recipient, please
delete and notify sender.
On 8/10/2016 8:04 PM, J. Paul. Manning wrote:
> Jared
>

I let the last direct correspondence by your client to mine slide but please have all contact go through the lawyers.
>

> Thanks
>

>J Paul
>

> Sent from my iPhone

Exhibit "A-4"
1

J. Paul. Manning
From:
Sent:
To:
Subject:

JP

Tim Castleman <timothycastleman@gmail.com>


Thursday, August 11, 2016 4:43 PM
J. Paul. Manning; Jared B. Hall; Kevin OConnor; Kevin OConnor; Kevin OConnor
Fwd: OConnor v Castleman

As far as I know, currently there is no request from Kevin or any court order requiring me to not to contact my
friend Kevin.
I also contacted you with the last email (see how it was addressed directly to you just like this one), your client
was sent a copy as a courtesy, since it directly affects him. Just like I am with this email, you know, like a friend
would do.
-

As far as I know, Pm under no legal or ethical restrictions (like I understand lawyers are) not to contact your
client, someone who apparently still considers me a friend (as judged by his current friendship status with me
via Facebook) and that as far I know I still have a personal friendship with (see your clients email from me
about this not being personal) and the fact he was in Lubbock and we hung out shortly before all of this
happened. If Im incorrect in that, and our friendship status has changed, Mr OConnor (and Mr OConnor alone)
can let me know that were no longer friends and I wont contact him again, but as of today, he hasnt done so
and thats why I continue to email him when important things occur.
Im sure you can see how confusing this could be with the mixed signals Im getting here, especially with zero
actual comments from Kevin or legal requirements here and just your request (which again, as far as I know, I
am under no legal obligation to follow).
Im also sure you have better things to do than dealing with this, but if Im incorrect, then please feel free to
have your client contact me and tell me that we are no longer friends and that he doesnt want me contacting
him anymore or file the necessary legal paperwork.
Maybe we can all be there in person and Kevin can explain the YouTube thing to us all at the same time?
That way your client doesnt have to appear in person, in court on at least two different occasions before the
actual legal trial starts.
I have to think those plane tickets from Ireland are pretty expensive and with this, the appeal, the trial, our
lawsuit against him, etc Im sure youll want to keep his out of pocket cost to a minimum and not charge him full
price for things like sitting and waiting 3 hours for a case to heard or something crazy like that.
-

Thanks for the email.


Tim Castleman, President, Castlman Consulting LLC

Exhibit "A-5"
I.

---------- Forwarded message ---------From: Tim Castleman <timothycastleman@gmail.com>


Date: Fri, Oct 7, 2016 at 10:05 PM
Subject: Heya Kevin (Lawsuit News)
To: Kevin O'Connor <Kevin@theofflineassistant.com>, Kevin O'Connor <kwoconnor@gmail.com>, Kevin
OConnor <theofflineassistant@gmail.com>

Kevin!
Man I haven't heard back from you since my last email - I hope everything is going ok my friend.
Listen, just wanted to let you know I sent off my check to the lawyer for our appeal to go through so the good
news is your lawyer gets to spend some more time in court on your behalf.
The court of appeals is a two hour drive each way from Lubbock (my guy is flying in direct from Houston) so at
your lawyers hourly rate the drive alone is going to cost you $1200.
Not to mention the actual paperwork for this appeal, sitting in court (remember the 3 hours he charged you last
time for just sitting there), and whatever else he has to do (like talk to you about the case, etc).
Think you'll finally break the $10k in lawyers fees with the appeal? Will JP really charge you $12k like he said
in last filing with the court.
My lawyer said he had one case that took 9 months to go in front of the court of appeals after all the paperwork
was filed. That's just crazy but due process is due process I guess.
And just think man, if somehow the appeal court doesn't side with us, then we have the actual trial and our
counter suit against you to go through and unlike this one, you'll actually have to appear in person, here in
Lubbock, several different times for hearings, etc for BOTH cases.
I doubt there are many discounted flights from Ireland to Lubbock Texas, but ifthere are I'll send them your
way.
Also the guy who swore under oath that he didn't do business with you because of my post - make sure he has
his passport ready as well because he'll have to make an appearance or two I suspect.
What do you think your final number is going to be in lawyers fees when this is all done? 15k or 20k??? Then
1

Exhibit "A-6"

you have travel cost and more for you.


And then you have the very real possibility of having to pay our lawyer fees as well as whatever judgement
(fine) they issue towards you ON TOP OF the 8k in orders you owe us for.
Man ... just thinking about this here and it could get really expensive.
It's annoying as hell for me (and expensive) as well, but you know me Kevin, I stand behind my word my friend
and since you refused to respond to my early request for settlement, I guess I'll just have to see this all the way
through like I promised you in the beginning.
Speaking of promises, thanks for no longer having our videos falsely blocked in Ireland. I'm sure the judge will
have a word with you about it during the trial but I just wanted to say thank you personally for doing that
because I hated having to constantly reload them and then take the added step of a new blog post, videos (that
can't be blocked) and more each time your team had my videos falsely blocked.
BTW, did you see this: http://www.timothycastleman.comlthe-offline-assistant-million-dollar-Iawsuit-againstmel
Since you kept blocking my videos I had no other choice to share my experience with your company than the
written word. Also, before you get all excited and try to have these removed as well - those are legal documents
and since you decided to sue me, they are all 100% public record and can't be taken down, removed, or blocked
and I have them on my own server as well so they will never go away.
I really didn't want to do that, but again, promises are promises and you screwed with my content even after I
told you not to and YOU left me no other option then to share what was going on in writing.
To me (and this is only my opinion with no basis of facts of course) the blog post reads like I hired a company
to do a job, I believe they did the job incorrectly (with pesky facts and spreadsheets to back it up), then when I
asked them to repay they went silent (you know like not returning emails and such) and then ended up suing me
for a million bucks less than 3 weeks later. Ok it was only $315k after 3 weeks, then went up to a million with
your second lawyer but I think you get the point.
I'm not sure ifI was thinking about doing business with a company like yours I'd like the fact that they not only
refused to admit fault, then went silent and refused to address the problem, and then went about trying to sue a
former client for $1,000,000 to silence them and their negative experience with the company would make me
want to do business with that company or not - but that's just my opinion and certainly not fact (until proven in
court of course).
Anyway my friend, looking forward to seeing you in Lubbock for the trial (if we somehow lose the appeal), and
I hope you bring your checkbook because I really don't want to have to go after your US clients to get repaid
and/or tell everyone that you lack the capital to pay your debts as a result of the lawsuit.
Hope you have a great weekend and let me know if you're doing ok. Your lack of email response has me
worried and I just want to make sure you're alive and well for the fun adventure ahead.
Tim

This email has been scanned for spam and viruses by Proofpoint Essentials. Click here to report this email as
spam.

From: Tim Castleman <timothycastleman@gmail.com>


Date: November 8, 2016 at 05:23:25 GMT
To: "Kevin O'Connor" <Kevin@theofflineassistant.com>, "Kevin O'Connor"
<kwoconnor@gmail.com>, Kevin OConnor <theofflineassistant@gmail.com>
Subject: Sad Panda :(

Kevin Man oh man the hits keep coming here buddy.


I mean we told your team in advance we were going to file the appeal, then we filed it and then
your team waited til the last possible day to request an extension of 30 days.
Turns out the judge only gave them 20 days which means we now have to wait til the end of
November to even submit your paperwork.
Plus they had to file the extension - all of which I am sure is costing you more money for the
extension along with them then having to file their answer.
But that's not all.
Because then we get 20 days to respond which puts us at the week of Christmas, which delays
everything even more because of the Christmas holiday and because your team asked for the
extra time.
You think the court will hear our case during that time or just push it to 20177
That means this entire process will have taken over a YEAR to get before the judge and if your
side somehow wins - then we have to start the actual court trial, appeal, counter suit, etc - you
already know all of this as does your lawyer who I am sure is more than happy to keep charging
you WAY more than it would have cost to settle with me.
Its interesting, here we are trying to get this thing over with and here your team keeps delaying
and delaying and delaying, I sure hope they're ready to explain that to the jury.
All the while people see the documents online, videos, podcast and more because apparently
(and this is just me guessing without any facts here) your lawyers can file the paperwork to sue
me for a million bucks, yet can't seem to handle when actual legal paperwork is handed to them
or they have to respond in a timely manner.
Just nuts right - especially at $300 an hour, you'd think they could hit a deadline for you and get
this thing wrapped up but nope, now we're going into 2017 it looks like due to your team.
It's cool, I mean after all, this is what you wanted right?
I really do hope it's worth it for you man. I mean here I offered to settle with you for 5k, which
you just ignored and now you've already spent double before we even get to a trial and there is a

Exhibit "A-7"

real possibility that you lose a legal case and have a legal judgement against you and then have to
pay me + a fine for filing the lawsuit, which will all be a matter of public record and anytime
anyone searches for you or your company it will be there.
Not to mention you still have to travel to Lubbock for the deposition, then the trial and explain
why you took down my videos and everything else.
See ya in 2017.
Tim

EXHIBIT B
21st September 2016 - Twitter
https://twitter.com/TimCastleman/status/778673004230258688

21st September
https://www.reddit.com/r/news/comments/53uvrz/the_offline_assistant_million_do
llar_lawsuit/?utm%5C_source=ifttt

13th September 2016:


http://www.timothycastleman.com/the-offline-assistant-million-dollar-lawsuitagainst-me/

9th September 2016 Video


https://www.youtube.com/watch?v=WfMLlgFVo1k&t=344s

6th September 2016 video


http://www.metacafe.com/watch/11427624/warning-stay-away-from-the-offlineassistant-company-kevin-o-connor-updated-9-6-16/

6th September 2016:


http://www.timothycastleman.com/warning-stay-away-from-the-offline-assistantcompany-kevin-oconnor-updated-9-6-16/
http://newscentral.exsees.com/item/b1560d8881b99144ea1df496d6bd015cf82f0ba38e40c6f66e3f773a1f5f079a

31st August 2016 Video


https://vimeo.com/180957904
https://vimeo.com/181662637 (asking people of Ireland to check out the video see the video description)

31st August 2016 video


https://www.youtube.com/watch?v=sry7ZIoPRaw&t=8s

22nd August 2016:


http://www.timothycastleman.com/warning-do-not-use-the-offline-assistantcompany-update-8-21-16/

2nd August 2016 (podcast)


http://www.timothycastleman.com/ep-51-two-drink-tim-podcast-being-sued-for-amillion-bucks-by-the-offline-assistant-company/

1st August 2016 - podcast


https://audio.simplecast.com/43569.mp3

8th March 2016


http://www.warriorforum.com/internet-marketing-product-reviewsratings/1140478-warning-do-not-use-offline-assistant-company-kevinoconnor.html?view=classic##post10575782

11/21/2016 TimCastlemanonTwitter:"Updateonthe$1millawsuitTheOfflineAssistantand@kevinWoconnorhaveagainstme:https://t.co/vAFgtuckIy#TheOfflin...

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me: timothycastleman.com/theofflineas
#TheOfflineAssistant
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2016Twitter

About Help Terms


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TheOfflineAssistantMillionDollarLawsuitAgainstMe:news

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submitted2monthsagobyLubbockGuy
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sortedby:best
[] tomjoads 1points2monthsago

Igiveashitaboutyourlawsuitswhy?
permalink

thispostwassubmittedon21Sep2016
1 point
https://redd.it/53uvrz

embed

[] LubbockGuy [S]1point2monthsago

WellTom,foronethingthisisacompanytrying
tobullyanothercompanytokeepquietbyhaving
theircontentillegallyremovedfromtheinternet&
tryingtosuethemintosilence.

username

password

rememberme

resetpassword

login

Iftheywin,thenyoucouldbelegallysuedand
heldresponsiblefornegativereviewsofbusinesses
thatyou'veusedandhadapoorexperiencewith.
Andifyoudospeakout,youwon'tbelegally
protectedtostateyouropiniononthesituation.
Isthatenoughtogiveashitabout?
permalink

embed

parent

[] tomjoads 1point2monthsago

NoIdon'tgiveashit,yourshittylifecoaching
companyisbeingsued.GoAstroTurf
somewhereelse
permalink

embed

parent

[] LubbockGuy [S]1point1monthago

Tom
Icantellalreadythatyou'reanidiot,but
atleasttrytobeasmartone.Idon'tdo
lifecoaching,Idohoweversellstuffonline
andhavebeenprettysuccessfulwithit.
Igetthatitmightnotbeforyou,most
peoplearen'twillingtodotheworktobe
successful,butI'mproudofwhatwe've
done.
Enjoyyourtrolling!
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11/21/2016

TheOfflineAssistantMillionDollarLawsuitAgainstMe|

SEPTEMBER 13, 2016

The Oine Assistant Million Dollar Lawsuit


Against Me
Since Kevin OConnors company The Oine Assistant keeps trying to get my
videos blocked in Ireland he has left me no choice but to share my personal
experience and these legal documents between us includinghis request for us
to pay up to a million dollars via his lawsuit against us.
After sharing my experience with Kevins company here (updated):
http://www.timothycastleman.com/warning-stay-away-from-the-oineassistant-company-kevin-oconnor-updated-9-6-16/ and how I believe his
company over ordered over $7,000 in products, he is now suing me for a million
dollars in civil court here in Lubbock Texas.
Here is the timeline of events.
After refusing to respond to my emails asking for repayment, I had no choice
but to retain a lawyer and send a demand letter requesting repayment:
Demand Letter To The Oine Assistant
DemandLettertotheOfflineAssistantbyTimCastlemanonScribd

http://www.timothycastleman.com/theofflineassistantmilliondollarlawsuitagainstme/

1/6

11/21/2016

TheOfflineAssistantMillionDollarLawsuitAgainstMe|

Not only did he not repay us (even after I oered to settle for $5,000, half the
amount my lawyer was requesting) his lawyer sent me a demand letter asking
for me to pay $315,000 in damages, to remove all of my post, videos, podcasts
and more that shared my experience with The Oine Assistant CompanyAND
wanted me to write an apology (that had to be approved by Kevin prior to
publishing) and post it here (and other locations) for an entire year.
Demand Letter Reply From The Oine Assistant Company
DemandLetterReplyFromtheOfflineAssistantCompanybyTimCastlemanonScribd

http://www.timothycastleman.com/theofflineassistantmilliondollarlawsuitagainstme/

2/6

11/21/2016

TheOfflineAssistantMillionDollarLawsuitAgainstMe|

When we refused to do so, he retained another attorney and is currently suing


me for up to a million dollars in civil court here in Lubbock Texas
The Oine Assistant Sues Me For A Million Dollars
TheOfflineAssistantSuesMeforaMillionDollarsbyTimCastlemanonScribd

http://www.timothycastleman.com/theofflineassistantmilliondollarlawsuitagainstme/

3/6

11/21/2016

TheOfflineAssistantMillionDollarLawsuitAgainstMe|

Filed 4/28/2016 3:06:57 PM

Barbara Sucsy
District Clerk

Lubbock County, Texas

cdm

CAUSE NO. 2016-519,740


INTERNET MONEY LIMITED d/b/a
THE OFFLINE ASSISTANT AND
KEVIN OCONNOR, INDIVIDUALLY,
Plaintiffs,
V.
TIMOTHY CASTLEMAN AND
CASTLEMAN CONSULTING, LLC,
Defendants.

IN THE 237THDISTRICT COURT

OF

LUBBOCK COUNTY, TEXAS

PLAINTIFFS FIRST AMENDED ORIGINAL PETITION

TO THE HONORABLE JUDGE OF SAID COURT:


NOW Comes INTERNET MONEY LIMITED D/B/A THE OFFLINE ASSISTANT

AND

KEVIN

OCONNOR, INDIVIDUALLY, hereinafter referred to as Plaintiffs, complaining of TIMOTHY


CASTLEMAN AND,CASTLEMAN CONSULTING, LLChereinafter referred to as Defendants, and

hereby respectfully shows unto the Court and Jury as follows:


I.
DISCOVERY CONTROL PLAN

Discovery is intended to be conducted under Level II pursuant to Rule 190.3.


II.
PARTIES

Plaintiff, INTERNET MONEY LIMITED d/b/a THE OFFLINE ASSISTANT, (Offline

I am only sharing this on my company blog here because Kevin and The Oine
Assistant Company keep attempting to have me silenced and my videos blocked
in Ireland.
My personal experience with The Oine Assistant company has been as follows:
Hired them to fulll our eCom store orders for our dropshipping store.
During a monthly review of my books, my accountant and I noticed close to
$8,000 in double orders by The Oine Assistant company on our behalf.

http://www.timothycastleman.com/theofflineassistantmilliondollarlawsuitagainstme/

4/6

11/21/2016

TheOfflineAssistantMillionDollarLawsuitAgainstMe|

When we confronted Kevin OConnor, the CEO of the company about this he
not only refused to accept responsibility, he stopped responding to my emails
once I started demanding repayment.
Left with no other options I retained a lawyer to ask for repayment via our
legal demand letter.
Kevin then hired not one, but two lawyers. The rst one wanted me to pay him
$315,000, give up my rst amendment rights (my opinion) and issue a public
apology (that had to be approved personally by Kevin) and his new lawyer now
wants me to pay up to $1,000,000 to Kevin and The Oine Assistant company.
This is my experience as President of Castleman Consulting LLC and should only
be considered my opinion until proven in a court of law. Do you own research
and due diligence prior to making any decision on doing business with The
Oine Assistant Company. I just wanted to share my experience with them.
These documents are a matter of public record and an ongoing legal case
against me and I am within my rights to publish them here.
Here is the video Kevin and The Oine Assistant Company are blocking from
Ireland viewers:

http://www.timothycastleman.com/theofflineassistantmilliondollarlawsuitagainstme/

5/6

11/21/2016

TheOfflineAssistantMillionDollarLawsuitAgainstMe|

00:00

44:33

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Warning: Stay Away From The Ofine Assistant Company &


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Warning: Stay Away From The Ofine Assistant Company & Kevin OConn...

Kevin appears to be intentionally trying to get all of my content blocked in Ireland instead of waiting
for the million dollar lawsuit he brought against us to nish here in the US Court System.
So for anyone who is in Ireland, here is the video unedited (and there is nothing Kevin can do to block
it)

http://newscentral.exsees.com/item/b1560d8881b99144ea1df496d6bd015cf82f0ba38e40c6f66e3f773a1f5f079a

1/7

11/21/2016

Warning:StayAwayFromTheOfflineAssistantCompany&KevinOConnorUpdated9.6.16

00:00 / 44:33

All content contained inside this video is a matter of public record and cause #2016-519, 740 here in
Lubbock Texas and does not violate any privacy or trademark issues.
All parties involved were in the United States at the time of this dispute and as such this content
cannot and should not be removed or restricted (say in Ireland for example) without court paperwork
per YouTube Policy.
All court paperwork should originate from the United States as that is where Kevin has sued my
company.
All statements made in the video are the opinion of Tim Castleman, Castleman Consulting LLC
President and should not be taken as factual without doing your own proper due diligence.
*** Update: Here is a video update of our on going dispute with Kevin OConnor and The Ofine
Assistant Company ***
Spoiler Alert: They are suing US for 1 million dollars and trying to get all of our content removed from
YouTube.
Heres the video update on YouTube: https://youtu.be/-ibf9UgJEUw
For those of you in Ireland (where Kevin is trying to block the content) here is the video:

http://newscentral.exsees.com/item/b1560d8881b99144ea1df496d6bd015cf82f0ba38e40c6f66e3f773a1f5f079a

2/7

11/21/2016

Warning:StayAwayFromTheOfflineAssistantCompany&KevinOConnorUpdated9.6.16

00:00 / 44:33

On November 18th, 2015 during a routine review of our books, our accountant noticed a $7,897.68
error caused by Kevin OConnors Ofine Assistant Company.
We hired Kevin and his company to fulll our physical product store orders and it turns out that they
had been double ordering and shipping our most popular item to customers at our expense for no
understandable reason.
Once the error was discovered, I immediately had the last 100 orders they had placed for us reviewed,
and there was an 85% error rate in those orders so we started to dig deeper.
I immediately let Kevin know about this issue personally and told him I would get him a full report by
the following Monday (this was Friday).
We pulled our nancial records from the store, the supplier, and matched them to our credit card
statements for them to get a full accounting of just how bad it was.
When all was said in done, Kevins employees had over ordered and shipped products to the tune of a
$14,968.45 almost DOUBLE what the orders should have cost and costing us $7,897.68 in prot.
Armed with this information I sent everything to Kevin and asked him to review everything and if the
numbers were correct explain why none of the orders were checked by his project manager (as
promised when we signed up) or anyone else on is staff for accuracy, how his employees could see us
losing money on ever order and not say anything, and why they hadnt followed the spreadsheet
directions we gave them.
When he nally responded 3 days later, he blamed us for not catching the error and cited a training
example order we included in the training materials (of a totally different product than the one they
misordered above) as a reason why they had doubled ordered everything.
Except they hadnt double ordered every item.
His team managed to order the correct quantities of other items we sold in different amounts (1, 2, 4
etc) with no problem.
When confronted with this, he went radio silent and refused to respond to any more of my emails.
It was only after I demanded repayment for the $7,897.68 error that he nally responded, and only to
tell me that he considered the matter closed on his part and that he and his employees had done
nothing wrong and that he wouldnt be paying for his employees mistake.
http://newscentral.exsees.com/item/b1560d8881b99144ea1df496d6bd015cf82f0ba38e40c6f66e3f773a1f5f079a

3/7

11/21/2016

Warning:StayAwayFromTheOfflineAssistantCompany&KevinOConnorUpdated9.6.16

So heres where we stand


Kevins company over ordered and shipped an additional $7,897.68 worth of products to my
customers which I now have to pay out of my own pocket
No one from his company (that we hired to manage this for us) reviewed any of the orders to ensure
they were being done correctly despite his assurances they do quality control and project
management on all jobs.
There was an 85% error rate by his staff in ordering products for us
When presented with facts (credit card statements, Shopify print outs, and AliExpress orders) Kevin
still refused to accept any responsibility and to this day has refused to pay me back for his company
and employees mistakes.
The money part stings, but heres the worst part.
I rst met Kevin when I and several others (Brad Gosse, Ron Douglas, E. Brian Rose, Ben Littleeld, Ben
Adkins, Colin Theriot, Mark Helton, Brian Anderson, Ryan McKinney) were his mentor at the Marketers
Mansion.
We all spent time with him trying to help him grow his business.
I personally promoted Kevin not only to my list via a webinar, but also through my podcast (free of
charge), and told several business associates about him (who ended up signing up with him right
Los).
Just last month I dropped everything when he came into town and showed him around Lubbock and
offered to help him even more with his company.
And this is how he repaid me and everyone else who helped him for doing so.
No apology, no acceptance of the facts, and most of all not a single offer to help us or compensate us
these errors.
I gotta assume that whole personal responsibility thing Garret White preaches didnt sink in with Kevin.
Now dont worry about me. Well be seeing Kevin in court and well get every cent (plus some) back
from him.
Im writing this post to warn others and share my personal experience with Kevin OConnor and his
company.
If you choose to use him after seeing that he doesnt stand behind his employees work, has zero
quality control or checks to ensure work is being done correctly, and no matter how much proof you
have of their mistakes, he will never admit when his team has made a mistake or compensate you in
any fashion for those mistakes go ahead.
If you want to host a webinar, podcast, or invite him to speak on stage after reading this, thats your
choice and speaks more to your core values than mine.
I just refuse to have people who have helped him in the past have their name associated with him or
his company without knowing the facts about what he did to our eCom business and his
unwillingness to stand behind his word and his employees mistakes.
Im just thankful that we have the cash reserves to not only absorb this temporary loss and but also
pursue every legal recourse against him.
In closing Ill share with you one last thought. Sometimes in life things like this happen. People
disappoint you, friendships end, and true colors are revealed. While you cant control when or why that
stuff happens, you can control your response to those situations.
I tried to resolve this in private, I gave Kevin every opportunity to make this right. It was only after he
refused to do so, and I saw how huge of a disaster this could be for people who dont have the same
http://newscentral.exsees.com/item/b1560d8881b99144ea1df496d6bd015cf82f0ba38e40c6f66e3f773a1f5f079a

4/7

11/21/2016

Warning:StayAwayFromTheOfflineAssistantCompany&KevinOConnorUpdated9.6.16

resources I do, that I knew I had to go public with this issue.


NewsCentral
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5/7

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Warning:StayAwayFromTheOfflineAssistantCompany&KevinOConnorUpdated9.6.16

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Warning:DoNotUseTheOfflineAssistantCompanyUpdate8.21.16|

AUGUST 22, 2016

Warning: Do Not Use The Oine Assistant


Company Update 8.21.16
Warning: Do Not Use The Ofine Assistant Company - Update 8.21.16

Kevin is intentionally trying to get all of my content blocked in Ireland instead of


waiting for the million dollar lawsuit he brought against us to nish.
So for anyone who is in Ireland, here is the video unedited (and there is
nothing Kevin can do to block it)

http://www.timothycastleman.com/warningdonotusetheofflineassistantcompanyupdate82116/

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11/21/2016

Warning:DoNotUseTheOfflineAssistantCompanyUpdate8.21.16|

00:00

44:33

All content contained inside this video is a matter of public record and cause
#2016-519, 740 here in Lubbock Texas and does not violate any privacy or
trademark issues.
All parties involved were in the United States at the time of this dispute and as
such this content cannot and should not be removed or restricted (say in Ireland
for example) without court paperwork per YouTube Policy.
All court paperwork should originate from the United States as that is where
Kevin has sued my company.
All statements made in the video are the opinion of Tim Castleman, Castleman
Consulting LLC President and should not be taken as factual without doing your
own proper due diligence.
Finally, hug a lawyer, they need it.
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Ep.51:TwoDrinkTimPodcastBeingSuedForAMillionBucksByTheOfflineAssistantCompany|

AUGUST 2, 2016

Ep. 51: Two Drink Tim Podcast Being Sued For A


Million Bucks By The Oine Assistant Company

Tim talks about being left for dead in Montreal, and how he is being sued for a
million bucks by Kevin OConnor & The Oine Assistant Company
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9thDec2015,10:48PM

TimCastleman

#1
Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor

Shareon:

Gunslinger
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JoinDate:2008
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OnNovember18th,2015duringaroutinereviewofourbooks,ouraccountantnoticeda$7,897.68errorcausedby
KevinOConnorsOfflineAssistantCompany.
WehiredKevinandhiscompanytofulfillourphysicalproductstoreordersanditturnsoutthattheyhadbeendouble
orderingandshippingourmostpopularitemtocustomersatourexpensefornounderstandablereason.
Oncetheerrorwasdiscovered,Iimmediatelyhadthelast100orderstheyhadplacedforusreviewed,andtherewas
an85%errorrateinthoseorderssowestartedtodigdeeper.
IimmediatelyletKevinknowaboutthisissuepersonallyandtoldhimIwouldgethimafullreportbythefollowing
Monday(thiswasFriday).
Wepulledourfinancialrecordsfromthestore,thesupplier,andmatchedthemtoourcreditcardstatementsforthem
togetafullaccountingofjusthowbaditwas.
Whenallwassaidindone,Kevinsemployeeshadoverorderedandshippedproductstothetuneofa
$14,968.45almostDOUBLEwhattheordersshouldhavecostandcostingus$7,897.68inprofit.
ArmedwiththisinformationIsenteverythingtoKevinandaskedhimtorevieweverythingandifthenumberswere
correctexplainwhynoneoftheorderswerecheckedbyhisprojectmanager(aspromisedwhenwesignedup)or
anyoneelseonisstaffforaccuracy,howhisemployeescouldseeuslosingmoneyoneverorderandnotsay
anything,andwhytheyhadntfollowedthespreadsheetdirectionswegavethem.
Whenhefinallyresponded3dayslater,heblamedusfornotcatchingtheerrorandcitedatrainingexampleorderwe
includedinthetrainingmaterials(ofatotallydifferentproductthantheonetheymisorderedabove)asareasonwhy
theyhaddoubledorderedeverything.
Excepttheyhadntdoubleorderedeveryitem.
Histeammanagedtoorderthecorrectquantitiesofotheritemswesoldindifferentamounts(1,2,4etc)withno
problem.
Whenconfrontedwiththis,hewentradiosilentandrefusedtorespondtoanymoreofmyemails.
ItwasonlyafterIdemandedrepaymentforthe$7,897.68errorthathefinallyresponded,andonlytotellmethathe
consideredthematterclosedonhispartandthatheandhisemployeeshaddonenothingwrongandthathewouldn
tbepayingforhisemployeesmistake.
Sohereswherewestand
Kevinscompanyoverorderedandshippedanadditional$7,897.68worthofproductstomycustomerswhich
Inowhavetopayoutofmyownpocket
Noonefromhiscompany(thatwehiredtomanagethisforus)reviewedanyoftheorderstoensuretheywere
beingdonecorrectlydespitehisassurancestheydoqualitycontrolandprojectmanagementonalljobs.
Therewasan85%errorratebyhisstaffinorderingproductsforus
Whenpresentedwithfacts(creditcardstatements,Shopifyprintouts,andAliExpressorders)Kevinstillrefused
toacceptanyresponsibilityandtothisdayhasrefusedtopaymebackforhiscompanyandemployees
mistakes.
Themoneypartstings,butherestheworstpart.
IfirstmetKevinwhenIandseveralothers(BradGosse,RonDouglas,E.BrianRose,BenLittlefield,BenAdkins,
ColinTheriot,MarkHelton,BrianAnderson,RyanMcKinney)werehismentorattheMarketersMansion.
Weallspenttimewithhimtryingtohelphimgrowhisbusiness.
IpersonallypromotedKevinnotonlytomylistviaawebinar,butalsothroughmypodcast(freeofcharge),andtold
severalbusinessassociatesabouthim(whoendedupsigningupwithhimrightLos).
JustlastmonthIdroppedeverythingwhenhecameintotownandshowedhimaroundLubbockandofferedtohelp
himevenmorewithhiscompany.

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Andthisishowherepaidmeandeveryoneelsewhohelpedhimfordoingso.
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Noapology,noacceptanceofthefacts,andmostofallnotasingleoffertohelpusorcompensateustheseerrors.

IgottaassumethatwholepersonalresponsibilitythingGarretWhitepreachesdidntsinkinwithKevin.
Nowdontworryaboutme.WellbeseeingKevinincourtandwellgeteverycent(plussome)back
fromhim.
ImwritingthisposttowarnothersandsharemypersonalexperiencewithKevinOConnorandhis
company.

Ifyouchoosetousehimafterseeingthathedoesntstandbehindhisemployeeswork,haszeroqualitycontrolor
checkstoensureworkisbeingdonecorrectly,andnomatterhowmuchproofyouhaveoftheirmistakes,hewill
neveradmitwhenhisteamhasmadeamistakeorcompensateyouinanyfashionforthosemistakesgoahead.
Ifyouwanttohostawebinar,podcast,orinvitehimtospeakonstageafterreadingthis,thatsyourchoiceand
speaksmoretoyourcorevaluesthanmine.
Ijustrefusetohavepeoplewhohavehelpedhiminthepasthavetheirnameassociatedwithhimorhiscompany
withoutknowingthefactsaboutwhathedidtooureCombusinessandhisunwillingnesstostandbehindhisword
andhisemployeesmistakes.
Imjustthankfulthatwehavethecashreservestonotonlyabsorbthistemporarylossandbutalsopursueevery
legalrecourseagainsthim.
InclosingIllsharewithyouonelastthought.Sometimesinlifethingslikethishappen.Peopledisappointyou,
friendshipsend,andtruecolorsarerevealed.Whileyoucantcontrolwhenorwhythatstuffhappens,youcan
controlyourresponsetothosesituations.
Itriedtoresolvethisinprivate,IgaveKevineveryopportunitytomakethisright.Itwasonlyafterherefusedtodoso,
andIsawhowhugeofadisasterthiscouldbeforpeoplewhodonthavethesameresourcesIdo,thatIknewI
hadtogopublicwiththisissue.

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9thDec2015,10:55PM

TimCastleman

#2
Re:Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor

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Alsobeforemodsgetpullhappyonthisthread...
ThisisareviewoftheserviceIpaidfor(Ihaveproofifyouneedit)andtheinteractionsIhadwiththeirowner(that's
whyheisnamed).
Ifthereisaproblemfeelfreetocontactme.Thanks.

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JamesCampbell

21stDec2015,01:38PM

Gregguitar

#3
Re:Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor

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Improvementjunkie

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OriginallyPostedbyTimCastleman
Alsobeforemodsgetpullhappyonthisthread...

JoinDate:2007
Location:Seattle,Wa.
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ThisisareviewoftheserviceIpaidfor(Ihaveproofifyouneedit)andtheinteractionsIhadwiththeirowner
(that'swhyheisnamed).
Ifthereisaproblemfeelfreetocontactme.Thanks.

23rdFeb2016,03:00PM

carlstaff
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JoinDate:2012

#4
Re:Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor

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11/21/2016

Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor
Location:TrophyClub,Texas
zendesksupportforScaleSocialandamazinglythesellerhasdisappeared.Anyoneknowwhathappenedto
Posts:2
1
StrategicallySpilledMilk?AndofcoursemyrefundrequestforScaleSocialisatPaypalbecausethesellerwillnot
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5thMar2016,09:34PM

atlantarobin

#5
Re:Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor

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7thMar2016,09:12PM

TimCastleman

#6
Re:Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor

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Gunslinger

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OriginallyPostedbyatlantarobin

ThishasNOTHINGtodowithRyMacsopleasetakeyourpitchforksandmoveonpleasetoyourownthread.
ThisthreadhaseverythingtodowithKevinO'ConnorandTheOfflineAssistantCompanyandthe$7,000theylost
duetopooroversightandinabilitytofollowthedirectionswesentthem.
Thanks.
Tim

23rdJul2016,02:55PM

BrentDotCom

#7
Re:Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor

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OriginallyPostedbyatlantarobin

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Warning:DoNotUseTheOfflineAssistantCompanybyKevinO'Connor
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updatesonthesituationandwillkeepdoingsoasitunfolds.
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